California Personal Injury and Bike Accident Attorney - Discovery; Written Interrogatories

RESERVED 50.0 CONTRACT
(Author's note: This questions 50.1 through 50.7 are asked in contract cases and will not be discussed here).

Question 50.1 For each agreement alleged in the pleadings: (a) identify all documents that are part of the agreement and for each state the name, address, and telephone number of each person who has the document; (b) state each part of the agreement not in writing, the name, address, and the telephone number of each person agreeing to that provision, and the date that part of the agreement was made; (c) identify all documents that evidence each part of the agreement not in writing and for each state the name, address and telephone number of each person who has the document; (d) identify all documents that are part of each modification to the agreement, and for each state the name, address, and telephone number of each person who has the document; (e) state each modification not in writing, the date, , and the name, address, and telephone number of each person agreeing to the modification, and the date the modification was made; (f) identify all documents that evidence each modification of the agreement not in writing and for each state stat the name address, and telephone number of each person who has the document.

Question 50.2 Was there a breach of any agreement alleged in the pleadings? If so, for each breach describe and give the date of every act or omission that you claim is the breach of the agreement.

Question 50.3 Was performance of any agreement alleged in the pleadings excused? If so, identify each agreement excused and state why performance was excused.

Question 50.4 Was any agreement alleged in the pleadings terminated by mutual agreement, release, accord and satisfaction, or novation? If so, identify each agreement terminated and state why it was terminated including dates.

Question 50.5 Is any agreement alleged in the pleadings unenforceable? If so, identify each unenforceable agreement and state why it is unenforceable.

Question 50.6 Is any agreement alleged in the pleadings ambiguous? If so, identify each ambiguous agreement and state why it is ambiguous.